Specific standard assurances are required by many federal funding agencies. In signing and submitting a proposal, the Vice Chancellor for Research and Sponsored Programs must certify The University of Mississippi’s compliance with federal requirements regarding lobbying; debarment, suspension and other responsibility matters; and drug-free workplace provisions. Most often, sponsors supply the institutional certification and assurance forms required as a part of the application package.
Public Law 101-121 states that applicants for federal funding must provide the following information on any contract, grant, or cooperative agreement exceeding $100,000:
- certification that no federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence a federal employee in connection with the appropriation of federal funds;
- submission of Standard Form-LLL Disclosure Form to Report Lobbying if non-federal funds are used to pay any person for influencing or attempting to influence a federal employee in connection with the appropriation of federal funds.
Debarment and Suspension
With the submission of an application for federal funding, an institution must certify or provide an explanation why it cannot certify that it and its principals, including consultants and subcontractors,
- are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from covered transactions by any federal department or agency;
- are not presently indicted for or have not within a three-year period preceding an application been convicted of or had a civil judgment rendered against them for commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public transaction or contract under a public transaction; violation of federal or state antitrust statutes or commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, or receiving stolen property; and
- have not within a three-year period preceding an application had one or more public transactions terminated for cause or default.
Drug-Free Workplace and Workforce
All grants or contracts made by a federal agency after March 18, 1989, require that applicant organizations assure the federal government that work on these projects will occur in a drug-free workplace. As part of the certification process, The University of Mississippi was required by law to develop a drug-free workplace policy which applies to all personnel engaged in the performance of a grant or contract funded with money from a federal agency. The policy also applies to undergraduate students and graduate students paid from funds acquired directly from a federal agency.
The policy states in part that
- the unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance is prohibited in the workplace;
- as a condition of employment employees must abide by the terms of the statement;
- any employee convicted of a drug violation occurring in the workplace is required to notify his/her immediate supervisor no later than five days after the conviction.
The policy outlines the sanctions which may be taken if an employee violates the policy. Such sanctions may include termination of employment, satisfactory completion of a rehabilitation program, or suspension.
Employees paid from funds granted from the U.S. Department of Defense (DOD) are subject to the requirements of the more comprehensive regulations of the DOD Drug-Free Workforce Rule of 1988. This Rule prohibits the use of controlled substances both on and off duty. As regards employees paid from DOD funds, UM also reserves the right to identify illegal drug users, including testing on a controlled and carefully monitored basis. UM also requires supervisors to discuss this policy with all employees working on DOD-funded contracts and grants.
The University of Mississippi Drug Free Workplace and Workforce Policy is found in the UM Policy Directory at https://secure4.olemiss.edu/umpolicyopen/ShowDetails.jsp?istatPara=1&policyObjidPara=10647941.
Note: All Principal Investigators and Project Directors must obtain a copy of the policy and inform their employees and contractors of its mandates as a requirement of administering any federally sponsored program.